Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
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Penalty under section 271(1)(c) could not survive once the underlying quantum addition, which formed the sole basis of the penalty, had already been deleted in the assessee's own case and that fact was not disputed by the Revenue. The Tribunal treated the penalty as purely consequential to the assessment addition and held that, without a surviving addition, there was no basis to sustain the penalty. The order sustaining the penalty was set aside and the penalty deleted.
Penalty under section 271(1)(c) could not survive once the underlying quantum addition, which formed the sole basis of the penalty, had already been deleted in the assessee's own case and that fact was not disputed by the Revenue. The Tribunal treated the penalty as purely consequential to the assessment addition and held that, without a surviving addition, there was no basis to sustain the penalty. The order sustaining the penalty was set aside and the penalty deleted.
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